### 1667 K Street NW, Suite 300 | Washington, DC 20006 | www.cspa.org | 202

- 872

- 8110

November 20 , 2012 via electronic transmission

Clerk of the Board

Air Resources Board

1001 I Street , 23 rd Floor

Sacramento, California 95814

http://www.arb.ca.gov/lispub/comm/bcl ist.php

Subject: 15

- Day Notice of Modifications to California Regulation for Automotive Windshield

Washer Fluid (AWWF) Products ; Board Resolution 12

- 32 1

Dear Board Members:

The Consumer Specialty Products Association (CSPA) 2 is on record supporting the amendments to

California Regulation related to the AWWF product category 3 and appreciates the oppor tunity to

offer comments on the modification set forth in Attachment B to Board Resolution 12

- 32. 4

CSPA supports the inclusion of an additional ZIP code in San B ernardino County to the Type “A”

area listed in Table 94508(a)(20)(B). As noted during the Board ’ s public hearing, this particular area

of San Bernardino County experiences freezing temperatures during the winter months. Thus, the

modification will further enhance public safety by eliminating potenti ally hazardous conditions that

c ould occur if : (1) the AWWF froze in the resident s ’ automobile windshiel d washe r reservoirs ; or

(2) froze when applied to the windshield while residents are driving

.

If you have any questions, plea se contact us at (202) 872

- 8110.

Respectfully submitted,

D. Douglas Frat z Joseph T. Yost

Vice President, Scientific & Technical Affairs Senior Director, Strategic Issues Advocacy

Kristin Power



### Director, State Affairs

– West Region

1 Board Resolut ion 12

- 32 is posted on the ARB website a t: http://www.arb.ca.gov/regact/2012/cp2012/res12

- 32.pdf

.

2 CSPA is a voluntary, non

- profit national trade association representing approximately 230 companies engaged

in the manufac ture, formulation, distribution, and sale of products for household, institutional, commercial and industrial

use. CSPA member companies' wide range of products includes home, lawn and garden pesticides, antimicrobial

products, air care products, automoti ve specialty products, detergents and cleaning products, polishes and floor

maintenance products, and various types of aerosol products. Through its product stewardship program Product Care ®

, and scientific and business

- to

- business endeavors, CSPA provide s its members a platform to effectively address issues

regarding the health, safety, sustainability and environmental impacts of their products.

3 CSPA filed written comments on October 15, 2012, and presented oral testimony at the Board’s public hearing

on October 18, 2012.

4 The text of Attachment B is posted on the ARB website at: http://www.arb.ca.gov/regact/2012/cp2012/cp2012.htm

.CSPA Comments on the 1 5

- Day Notice of Modifications to Board Resolution 12

- 32

November 20, 2012

Page 2 of 2

cc: Carla D. Takemoto

, Chief, Area Source and Emissions Inventory Programs Branch , PTSD

Jose Gomez

, Manager, Technical Development Section

, Area Source and Emissions

Inventory Programs Branch , PTSD

Olufemi Olaluwoye, Air Pollution Specialist, Technical Develo pment Section

, Area Source

and Emissions Inventory Programs Branch , PTSD

CS PA Air Quality Special Committee and Automotive Products Task Force

Laurie E. Nelson, Randlett Nelson Madden Associates